Battery passport: the 71 data points required, and those that are not yet
The Commission published its list of the 71 data points of the battery passport on 21 August 2026, with the status of each one per category. What applies on 18 February 2027, what does not, and where the data comes from.
What the Commission published on 21 August 2026
The Directorate-General for Internal Market updated its guidance document Digital Batteries Passport, data points by category. It brings together 71 data points and states, for each one, whether it is mandatory, optional, applicable only in specific circumstances, or not to be completed or displayed as of 18 February 2027, battery category by battery category.
Two reading precautions. The document states itself that it introduces no new requirements and is not an authoritative interpretation of the regulation: where in doubt, the text of the regulation applies. And it is announced as evolving, with later versions expected to specify units of measurement and declaration formats to improve comparability between manufacturers.
It is therefore a working tool, not a source of obligations. Its value lies elsewhere: it prevents the assumption that everything is due at the same time.
The passport is mandatory on 18 February 2027
Article 77 of Regulation (EU) 2023/1542 sets the obligation. Three families are covered, and two are not:
| Category | Scope | Passport |
|---|---|---|
| Electric vehicle batteries | All | 18 February 2027 |
| Light means of transport batteries (e-bikes, e-scooters, e-mopeds) | All | 18 February 2027 |
| Industrial batteries | Capacity above 2 kWh | 18 February 2027 |
| Portable batteries | All | Not covered |
| Starting, lighting and ignition (SLI) batteries | All | Not covered |
Both exclusions are frequently reported the wrong way round, including in compliance guides: portable device batteries and SLI batteries are outside the passport. The scheme covers the three families at the top of the table, and those only.
The obligation falls on the economic operator placing the finished battery on the market, normally the EU manufacturer or the importer. Not on the cell supplier, not on the module supplier. The same article requires that operator to ensure the information is accurate, complete and up to date, and to keep the passport accessible for the battery's entire lifetime. When a battery is re-used, repurposed or remanufactured, the obligation passes to the new operator, with a passport linked to the original. The passport ceases to exist once the battery is recycled.
Annex XIII is not a flat list
The annex organises the information in four parts, and that structure determines who sees what:
- Part 1: model information, publicly accessible through the QR code.
- Part 2: detailed model information, restricted to persons with a legitimate interest.
- Part 3: test reports and conformity evidence, restricted to notified bodies, market surveillance authorities and the Commission.
- Part 4: information specific to the individual battery, including data arising from its use, open to persons with a legitimate interest.
What "71 data points" means for your collection plan
The Commission's document places each point in one of four situations:
| Status | What it implies |
|---|---|
| Mandatory | To be completed for the category concerned, without exception |
| Optional | The manufacturer may provide it, nothing requires it |
| Circumstantial | Due only for certain technologies or uses |
| Not applicable as of 18 February 2027 | Must not be completed or displayed on that date |
The practical consequence is simple and counter-intuitive: a collection plan built on all 71 points puts teams to work on data that is not due in February 2027. The right starting point is the "mandatory" column for your category, not the full list.
Three obligations with their own timetable
The passport applies in February 2027. Its content does not. Three related but distinct obligations follow their own rhythm, and each can slip if the Commission's implementing acts are not yet in force.
- Carbon footprint (Article 7): the declaration is mandatory for electric vehicle batteries since 18 February 2025, for rechargeable industrial batteries above 2 kWh since 18 February 2026, and for light means of transport batteries from 18 August 2028. Each of those dates reads "or eighteen months after the corresponding acts enter into force, whichever is later".
- Recycled content (Article 8): documenting the shares of recycled cobalt, lead, lithium and nickel becomes mandatory on 18 August 2028 for electric vehicle, industrial and SLI batteries, and on 18 August 2033 for light means of transport batteries. Minimum thresholds follow in 2031.
- Supply chain due diligence: applicable from 18 August 2027.
Where the data comes from, and why that is the real difficulty
No single company holds the full set. Identification data, electrical characteristics and the declaration of conformity come from the assembler. Composition, critical raw materials above 0.1 % by weight and hazardous substances come from cell and material suppliers. State of health comes from the battery itself, through its management system, fed during use.
That is what separates the battery passport from a conventional documentation exercise. The QR code takes days to arrange. Data from two tiers upstream has to be requested, negotiated and corrected over months, often in another language, often without an imposed format. Companies that approach the subject technically, choosing a tool first, end up publishing a passport empty of its most useful data.
The access rights of repairers and recyclers are not settled yet
Article 77(9) requires the Commission to specify by implementing act who the persons with a legitimate interest are, which information in the annexes they may access, and to what extent they may download, share and re-use it. The regulation set a deadline of 18 August 2026 for that act.
At our check on 10 October 2026, the act had not been published, and the Commission's indicative timeline points to the fourth quarter of 2026. This does not shift the passport itself, whose date remains 18 February 2027, but it leaves a structural question open for everyone except the general public: the exact extent of restricted access. It is worth designing access management flexibly enough to absorb the decision when it lands.
The registry has been operational since 20 July 2026
The digital product passport registry, established under the ecodesign regulation and implemented by Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026, has been operational since 20 July 2026. The system remains decentralised: information is hosted by the responsible operator, while the registry holds the identifiers and makes each passport findable.
The practical consequence is often underestimated. The passport must remain accessible for the battery's entire lifetime, including after a change of provider, a change of company name or the discontinuation of a product line. Hosting you do not fully control becomes a legal weak point, since you are the one answerable for the accuracy and availability of the information.
What to do now
1. Map the models concerned, with their category and capacity. That determines which row of the 71 points applies to you.
2. Extract the mandatory points for your category as of 18 February 2027, and leave the rest aside for now.
3. Identify who holds each piece of data: in-house, cell supplier, material supplier, battery management system.
4. Open the supplier requests first. Those are the longest lead times, and they are not yours to control.
5. Publish a test passport on one model, now, to see what is genuinely missing rather than inferring it from a spreadsheet.
DPPify supports the battery passport fields, the public page accessible by QR code, export of your data and a credential aligned with the UNTP standard. The free plan covers five published passports, which is enough to test one model and measure the gap.
For the wider picture and the timetable of the sector's other obligations, see our article Battery DPP: understanding the 2027 regulatory obligation. And if you are starting from scratch, begin with what a digital product passport is.
Sources
- Regulation (EU) 2023/1542 — Article 77 and Annex XIII, EUR-Lex
- Digital Batteries Passport, data points by category — European Commission, DG GROW, version of 21 August 2026
- Commission Implementing Regulation (EU) 2026/1778 of 16 July 2026 — arrangements for the DPP registry, EUR-Lex
- Digital product passport, batteries — European Commission, implementation timeline
References and dates checked on 10 October 2026. This article describes a regulatory framework still being finalised: it is not legal advice.